MENU

Disclosures

In order to comply with the sustainable finance disclosure regulation (SFDR)*. TLF Ventures GP (TLF) makes the following disclosures.

Integration of sustainability risks (Article 3 (1) of the SFDR)
A sustainability risk means "an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment" (Article 2(22) of the SFDR).

Before any investment decisions are made on behalf of a fund that TLF manages, an investment decision process is followed which, in regard to specific investments, includes the approval of the Investment Committee of such fund. TLF views sustainability as a standard topic in the pre- investment process. Part of the investment decisions process is that TLF assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by TLF when making investment decisions.

In addition, TLF implements a performance-based policy while reviewing its employees. TLF considers compliance with all policies and procedures which are in effect within TLF, including the ESG policy manual which defines TLF’s commitment to Environmental, Social and Governance (ESG) matters and which outlines how TLF integrates ESG into investment and portfolio monitoring activities.

Employees are made aware of the applicable policies and procedures when starting their employment with TLF.

No consideration of adverse sustainability impacts at entity level (Article 4 (b) of the SFDR)

TLF does not consider adverse impacts of investment decisions on sustainable factors at entity level within the meaning of article 4 sub 1 (b) of the SFDR. Hence, TLF does not make the disclosures as described in article 4 sub 1(a) of the SFDR. Considering the aggregate assets under management at TLF level, it has been determined that it wouldn’t be proportional to consider adverse sustainability impacts (PAI) at entity (i.e. TLF) level. For the avoidance of doubt, this wouldn’t prevent TLF from considering PAI at fund level to the extent disclosures to this effect are included in the SFDR pre-contractual disclosures of the relevant fund.

***

*Regulation (EU) 2019/2088